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entitled 'Millennium Challenge Corporation: Review of Compact Records
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United States Government Accountability Office:
GAO:
Report to the Ranking Member, Subcommittee on State, Foreign
Operations, and Related Agencies, Committee on Appropriations, U.S.
Senate:
June 2013:
Millennium Challenge Corporation:
Review of Compact Records and Information Management Program:
GAO-13-615:
GAO Highlights:
Highlights of GAO-13-615, a report to the Ranking Member, Subcommittee
on State, Foreign Operations, and Related Agencies, U.S. Senate.
Why GAO Did This Study:
MCC has approved 26 bilateral compact agreements, providing a total of
about $9.3 billion to help eligible developing countries reduce
poverty and stimulate economic growth. MCC is subject to the Federal
Records Act, which requires that agencies preserve all records
documenting its functions and other important transactions.
GAO was asked to review MCC’s management of records and information.
This report (1) examines MCC’s records and information management
program and practices and (2) assesses partner governments’
implementation of MCC’s information retention guidelines. GAO analyzed
MCC documents, interviewed MCC officials, and tested MCC’s ability to
retrieve compact-related information from five closed compacts. GAO
selected these compacts because they closed after May 2011, when MCC’s
Program Closure Guidelines went into effect.
What GAO Found:
In 2006, the Millennium Challenge Corporation (MCC) established a
records and information management program to maintain and preserve
its federal records. The program includes policies related to compact
management records—-a subset of MCC’s federal records. These policies
also address the handling of other compact-related information
generated by MCC partner governments’ accountable entities, which
typically manage compact implementation until the 5-year compacts
close. MCC’s policies require that the entities transfer their compact
management records to MCC for storage before compact closure. MCC also
requires that partner governments retain compact-related information
not classified as records, such as survey data and data quality
reviews, for at least 5 years after their compacts close, to
facilitate audits and analysis of MCC assistance. However, MCC does
not require, and has not conducted, periodic reviews to determine
whether it has received all compact-management records from the
accountable entities consistent with federal internal control
standards. As a result, MCC cannot be sure that it is meeting the
federal requirement that it preserve all records documenting its
functions, activities, and other transactions.
In reviews of five closed compacts—-Armenia’s, Benin’s, El Salvador’s,
Ghana’s, and Mali’s—-GAO found variation in the accountable entities’
implementation of MCC document retention requirements and the partner
governments’ ability to retrieve requested compact-related information
after the compacts closed. As required by MCC’s compact closure
guidelines, all five program closure plans that we reviewed contained
some discussion of retaining and storing documents, but each
accountable entity addressed the guidelines’ requirements differently.
MCC’s guidelines do not provide a list specifying standard types of
compact-related information that most compacts should retain. Such
variation in approaches to retaining and storing compact-related
information will make it more difficult for MCC to verify that
standard compact information is retained in all partner countries
after the compacts close. In addition, in a test of MCC’s ability to
retrieve documents from the partner governments after compact closure,
GAO found that four of the five governments provided all or most
requested documents within 30 days, but Mali’s, which is involved in
political turmoil, provided no documents (see figure). Political
turmoil in Madagascar, another compact-recipient country, has also
impeded MCC’s ability to obtain compact information that may be needed
to conduct future audits, evaluate project impact, or inform future
compact designs.
Figure: Number of Documents Returned to GAO within 30 Days, by Country:
[Refer to PDF for image: stacked horizontal bar graph]
MCC country: Armenia;
Number of documents requested: 13;
Number of documents received: 15.
MCC country: Benin;
Number of documents requested: 20;
Number of documents received: 20.
MCC country: El Salvador;
Number of documents requested: 14;
Number of documents received: 18.
MCC country: Ghana;
Number of documents requested: 17;
Number of documents received: 20.
MCC country: Mali;
Number of documents requested: 0;
Number of documents received: 20.
Source: GAO.
[End of figure]
What GAO Recommends:
To strengthen MCC’s records and information management program, MCC’s
Chief Executive Officer should (1) develop a policy requiring—-and
conduct--periodic reviews of MCC’s compact-management records to
ensure they are complete, (2) revise guidelines to include a sample
document retention schedule specifying standard types of compact-
related information compacts should retain, and (3) review MCC’s
policy of delegating storage of most compact-related information to
partner governments. MCC agreed with all three recommendations and
stated that they have already taken steps to implement them.
View [hyperlink, http://www.gao.gov/products/GAO-13-615]. For more
information, contact David Gootnick at (202) 512-3149 or
gootnickd@gao.gov.
[End of section]
Contents:
Letter:
Background:
MCC Has Established a Records and Information Management Program but
Has Not Reviewed Its Inventory of Compact-Management Records:
Partner Countries' Implementation of MCC Document Retention
Requirements and Their Ability to Provide Requested Documents Vary:
Conclusions:
Recommendations:
Agency Comments and Our Evaluation:
Appendix I: Objectives, Scope, and Methodology:
Appendix II: MCC Scores on NARA Self-Assessment Survey, 2009-2012:
Appendix III: Comments from the Millennium Challenge Corporation:
Appendix IV: GAO Contact and Staff Acknowledgments:
Tables:
Table 1: Descriptions of MCC Compact Management Records and Other
Compact-Related Information:
Table 2: MCC's Score on 2012 NARA Survey, by Section:
Table 3: Selected USAID Office of the Inspector General Audit Reports,
by Title and Number:
Table 4: Number of Documents in Random Sample, per MCC Compact and
Type of Audit:
Table 5: MCC Scores on NARA Self-Assessment Survey, by Section, 2009:
Table 6: MCC Scores on NARA Self-Assessment Survey, by Section, 2010:
Table 7: MCC Scores on NARA Self-Assessment Survey, by Section, 2011:
Table 8: MCC Scores on NARA Self-Assessment Survey, by Section, 2012:
Figure:
Figure 1: Number of Requested Documents Returned within 30 Days, by
Country:
Abbreviations:
FOIA: Freedom of Information Act:
OIG: Office of the Inspector General:
MCA: Millennium Challenge Account:
MCC: Millennium Challenge Corporation:
NARA: National Archives and Records Administration:
USAID: United States Agency for International Development:
[End of section]
GAO:
United States Government Accountability Office:
441 G St. N.W.
Washington, DC 20548:
June 20, 2013:
The Honorable Lindsey Graham:
Ranking Member:
Subcommittee on State, Foreign Operations, and Related Agencies:
Committee on Appropriations:
United States Senate:
Dear Senator Graham:
The Millennium Challenge Corporation (MCC), a U.S. government
corporation, provides aid to developing countries that have
demonstrated a commitment to ruling justly, encouraging economic
freedom, and investing in people. MCC provides its assistance to
eligible countries through 5-year compact agreements with the specific
goal of reducing poverty by stimulating economic growth. Since its
establishment in 2004, MCC has signed 26 compacts with the governments
of 25 low-income or lower-middle-income countries, committing
approximately $9.3 billion for compact assistance.[Footnote 1] The
partner governments vest accountable entities, generally referred to
as Millennium Challenge Accounts (MCAs), with responsibility for
implementing the compacts, including managing compact records and
other information, in accordance with MCC policies and guidelines.
The Federal Records Act of 1950, as amended, requires each federal
agency, including MCC, to make and preserve records that, among other
things, document the agency's decisions, procedures, and essential
transactions.[Footnote 2] Since 2009, the National Archives and
Records Administration (NARA) has required agencies to complete an
annual self-assessment of their records management practices, which it
uses to rate the agencies' compliance with the Federal Records Act and
other laws and regulations related to records management. As our
previous work has shown, agencies with poorly managed records risk
increased costs when attempting to search their records in response to
Freedom of Information Act (FOIA) requests or litigation-related
discovery actions. Without effective management of the documentation
of government actions, the ability of the people to hold the
government accountable is jeopardized.[Footnote 3] In addition,
effective records management is an important tool for efficient
government operation; without adequate and readily accessible
documentation, agencies may not have access to important operational
information to make decisions and carry out their missions.[Footnote 4]
You asked us to review MCC's approach to records management, including
its practice of delegating the retention and storage of most compact-
related information to partner governments. This report (1) examines
MCC's records and information management program and practices and (2)
assesses partner governments' implementation of MCC guidelines for
retention and storage of compact-related information.
To describe MCC's approach to records management, we reviewed NARA's
records-management guidance and the self-assessment survey that NARA
administers to assess agencies' compliance with federal requirements.
We also reviewed MCC's policies and procedures and interviewed
cognizant officials at MCC and NARA. To assess the extent to which
MCAs have implemented MCC's guidelines for information retention, we
selected five closed MCC compacts--with Armenia, Benin, El Salvador,
Ghana, and Mali--to use as case studies.[Footnote 5] We reviewed
certain documentation compiled by each MCA or partner government in
accordance with MCC's guidelines[Footnote 6] and conducted a test of
MCC's ability to retrieve compact-related information after compact
closure. For this test, we drew a random sample of MCA documents that
had been used for audits conducted by the U.S. Agency for
International Development's (USAID) Office of the Inspector General in
our case-study countries.[Footnote 7] We provided MCC with a list of
about 20 documents[Footnote 8] for each case-study country and asked
that the partner governments provide the documents to us within a
specific timeframe. (See appendix I for further details of our scope
and methodology.)
We conducted this performance audit from September 2012 to June 2013
in accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe
that the evidence obtained provides a reasonable basis for our
findings and conclusions based on our audit objectives.
Background:
In accordance with the Federal Records Act and NARA's implementing
regulations for records management and retention, MCC is responsible
for managing the records that it generates. MCC has established
policies and issued guidance intended to ensure that the records
generated by the governments receiving compact and threshold
assistance are properly identified and transferred to MCC for storage
and management.[Footnote 9]
Federal Records Act Requirements:
The Federal Records Act, as amended,[Footnote 10] requires each
federal agency to make and preserve records that (1) document the
organization, functions, policies, decisions, procedures, and
essential transactions of the agency; and (2) provide the information
necessary to protect the legal and financial rights of the government
and of persons directly affected by the agency's activities.[Footnote
11] Such records must be managed and preserved in accordance with the
act's provisions.
To ensure that they have appropriate systems for managing and
preserving their records, the act requires agencies to develop records
management programs.[Footnote 12] These programs are intended, among
other things, to provide for accurate and complete documentation of
the policies and transactions of each federal agency, to control the
quality and quantity of records they produce, and to provide for
judicious preservation and disposal of federal records. A records
management program identifies records and sources of records and
provides records management guidance, including agency-specific
recordkeeping practices that establish what records need to be created
to conduct agency business, among other things.
NARA Records Management Oversight and Requirements:
Under the Federal Records Act, NARA has general responsibilities for
oversight of agencies' federal records management.[Footnote 13] These
responsibilities include issuing guidance for records management;
working with agencies to implement effective controls over the
creation, maintenance, and use of records in the conduct of agency
business; providing oversight of agencies' records management
programs; approving the disposition (destruction or preservation) of
records; and providing storage facilities for agency records on a fee-
for-service basis.
NARA has issued regulations requiring that records be effectively
managed throughout their life cycle, including records creation and
receipt, maintenance and use, and disposition. One key records
management process is scheduling, the means by which NARA and agencies
identify federal records and determine timeframes for disposition.
Creating records schedules involves identifying and inventorying
records, appraising their value, determining whether they are
temporary or permanent, and determining how long they should be kept
before they are destroyed or turned over to NARA for archiving.
Scheduling records requires agencies to invest time and resources to
analyze the information that an agency receives, produces, and uses to
fulfill its mission. Such an analysis allows an agency to set up
processes and structures to associate records with schedules and other
information to help it find and use records during their useful lives
and dispose of those no longer needed. Scheduling involves broad
categories of records rather than individual documents or file folders.
Since 2009, NARA has required federal agencies to complete an annual
self-assessment of their records management practices, to determine
whether the agencies are compliant with statutory and regulatory
records management requirements. The 2012 self-assessment survey
called for agencies to evaluate themselves in four areas: (1) records
management activities, (2) oversight and compliance, (3) records
disposition, and (4) electronic records. NARA scores the self-
assessments, and the accompanying agency documentation, and uses the
scores to categorize each agency as low, moderate, or high risk in
terms of compliance with federal regulations.
MCC Has Established a Records and Information Management Program but
Has Not Reviewed Its Inventory of Compact Management Records:
Beginning in 2006, MCC established a records and information
management program and subsequently established guidelines for
handling compact management records and other compact-related
information. However, MCC has not created a policy for--or conducted--
periodic reviews of the extent to which it has received the compact
management records that it requires MCAs to provide to MCC for
storage. In 2012, MCC's score on the NARA survey placed the agency in
the moderate risk category--an average rating--for compliance with
federal requirements.
MCC's Records and Information Management Program Includes Guidelines
Defining Records:
MCC established its records and information management program in
2006.[Footnote 14] The program's stated objectives, according to the
2011 version of its Records and Information Management Policy, are to
create, maintain, and preserve adequate and proper documentation of
its policies, transactions, and decisions; ensure the security and
integrity of MCC's federal records, including the safeguarding of
records against unauthorized access or disposition; and prevent the
removal of records and control the removal of other materials from the
agency.
MCC's Records and Information Management Policy defines "federal
record" consistently with the Federal Records Act's definition of
"record." According to the policy, MCC catalogs its federal records
into four major series, based on the records' functions.[Footnote 15]
* Administrative: Records commonly found at any federal agency, such
as accounting and finance files, and budget, personnel, and
procurement files.
* Governance: Records related to the Millennium Challenge Act of 2003,
authorities, laws, and legislation, such as Board of Directors meeting
minutes and resolutions, legal opinions, and ethics program records.
* Communications: Exchanges with external entities, such as MCC's
annual report, congressional notifications, press releases, and
official speeches, among other things.
* Millennium Challenge Account Assistance: MCC mission development,
implementation, oversight, results, and closeout information
pertaining to threshold programs and compacts. This category also
includes compact management records, which are generated at least in
part by the MCAs.
MCC Has Issued Guidance for Managing Compact Management Records and
Other Compact-related Information:
MCC provides guidance regarding the maintenance of compact management
records and the retention and storage of compact-related information.
In 2007, MCC issued Policy and Procedures for Compact-Related Federal
Recordkeeping,[Footnote 16] which was updated in 2012. The policy
outlines specific policies and procedures regarding compact management
records--which MCC refers to as a subset of federal records--and other
compact-related information.[Footnote 17] The policy also includes a
list specifying the types of documents that MCC classifies as compact
management records. The policy and procedures apply regardless of
whether the records and other compact-related information are created
by MCC staff, partner governments, MCA entities, contractors, or other
parties.[Footnote 18]
* Maintenance of compact management records. According to MCC's Policy
and Procedures for Compact-Related Federal Recordkeeping, all
information defined as a compact management record must be maintained
at MCC headquarters during compact development and implementation and
after compact closure. For example, under the policy, the following
monitoring and evaluation documents are classified as compact
management records, to be maintained at headquarters: indicator
tracking tables, monitoring and evaluation plans and revisions,
reviews and final impact evaluations, and data quality reviews.
* Retention and storage of compact-related information. MCC's Policy
and Procedures for Compact-Related Federal Recordkeeping further
states that the partner governments must retain, for at least 5 years
after compact closure, types of information that are not defined as
records but are important to the implementation and closure of
compacts.[Footnote 19] The policy specifies, as examples of such
information, (1) documents to support audits by MCC's Office of the
Inspector General and GAO and (2) program evaluation documents to
support ongoing analysis of MCC assistance. In another policy
document, Program Closure Guidelines, MCC also requires MCAs to
provide to MCC certain compact-related information for storage at MCC
headquarters. For example, MCAs are required to provide the following
information related to compact monitoring and evaluation: all MCC-
funded survey data sets and supporting materials, such as
questionnaires, enumerator field guides, data entry manuals, data
dictionaries, and final reports; other analyses; evaluations; and data
quality reviews and special studies that were funded through the
compact's monitoring and evaluation budget.
Table 1 describes compact management records and other compact-related
information.
Table 1: Descriptions of MCC Compact Management Records and Other
Compact-Related Information:
Type of information: Compact-management records;
Description: A subset of the Millennium Challenge Account Assistance
series of federal records that must be maintained by MCC headquarters
during implementation and after compact closure.
Compact-related information: To be retained by partner governments for
at least 5 years after compact closure;
Description: Documents that may be needed to support future audits or
analysis of MCC assistance.
Compact-related information: To be provided by MCAs for storage by MCC
headquarters;
Description: Documents or copies of documents that must be provided to
MCC during implementation or at compact closure, such as survey data
sets and supporting materials.
Source: GAO analysis of guidance from MCC, Policy and Procedures for
Compact-Related Federal Recordkeeping (2012) and Program Closure
Guidelines (2011).
[End of table]
MCC's Policy and Procedures for Compact-Related Federal Recordkeeping
assigns the responsibility for ensuring that the country's compact
management records are transmitted and received at MCC headquarters to
the MCC Resident Country Director serving in each partner country.
[Footnote 20] The policy states that MCC has the responsibility to
ensure that MCAs are taking reasonable steps to meet records
management requirements. The policy also states that MCC is
responsible for ensuring that the partners understand (1) what is
covered by both compact management records and other compact-related
information and (2) that MCC or a U.S. government audit, legal, or
oversight entity may need to have access to such information for at
least 5 years after the compact end date.
MCC Has Not Reviewed Its Compact Management Records for Completeness:
MCC policy does not call for, and MCC has not performed, reviews of
the extent to which it has received the compact management records
that it requires MCAs to provide to MCC for storage. According to
Standards for Internal Control in the Federal Government,[Footnote 21]
a federal agency should have in place control activities--that is,
policies, procedures, techniques, and mechanisms, including reviews of
performance--to help ensure that management's directives are carried
out. MCC's Policy and Procedures for Compact-Related Federal
Recordkeeping assigns to the MCC Resident Country Director in each
partner country the responsibility for ensuring the transmittal and
receipt of the country's compact management records at MCC
headquarters. However, MCC policy does not require periodic reviews of
the records received from the MCAs to ensure that all required records
have been transferred. In addition, MCC's Records Management Officer
stated that MCC has not reviewed the compact management records it has
received, for the following reasons: (1) the first compacts ended only
recently, and (2) the records management program has limited
resources. However, of the 11 compacts that have closed or been
terminated, 5 ended in 2011 and 2 ended in 2010. Without periodically
reviewing the compact management records it receives from the MCAs,
MCC cannot be sure that it is meeting the Federal Records Act's
requirement that it preserve all records documenting its functions,
activities, decisions, and other important transactions.
MCC's Records Management Program Received an Average Rating on NARA
Survey in 2012:
In 2012, MCC received a revised score of 77 out of 100 on NARA's self-
assessment survey, which placed MCC in the moderate risk category in
terms of compliance with federal requirements (see table 2). A NARA
official characterized this score as an "average rating" for federal
agencies. In the previous 3 years, MCC received the following scores:
92 (2009), 83 (2010), and 76 (2011) (see appendix II for more
information.) MCC's Records Management Officer also stated that
meeting NARA requirements, especially for electronic records, is
difficult for small federal agencies with limited resources and that
MCC, in conjunction with other small agencies, has appealed to NARA
for assistance.[Footnote 22]
Table 2: MCC's Score on 2012 NARA Survey, by Section:
Survey section: Records management activities;
MCC points received: 21;
Total possible points: 21;
Percentage: 100%.
Survey section: Oversight/compliance;
MCC points received: 23;
Total possible points: 31;
Percentage: 74%.
Survey section: Records disposition;
MCC points received: 15;
Total possible points: 15;
Percentage: 100%.
Survey section: Electronic records;
MCC points received: 18;
Total possible points: 33;
Percentage: 55%.
Survey section: Total score;
MCC points received: 77;
Total possible points: 100;
Percentage: 77%.
Source: GAO analysis of MCC results on the NARA survey.
[End of table]
Partner Countries' Implementation of MCC Document Retention
Requirements and Their Ability to Provide Requested Documents Vary:
For the five closed compacts that we reviewed--MCC's compacts with
Armenia, Benin, El Salvador, Ghana, and Mali--the MCAs provided
varying levels of detail about their plans for retaining compact-
related information to address MCC requirements. In addition, the five
partner governments showed varying capacity to provide the documents
that we asked MCC to retrieve.
MCAs Provided Varying Levels of Detail about Document Retention Plans:
* For the five compacts that we reviewed, the MCAs provided varying
levels of detail about their plans for retaining compact-related
information. MCC's Program Closure Guidelines instruct accountable
entities to develop program closure plans describing their strategy
for retaining and storing compact-related information. The guidelines
state that each accountable entity should provide the following three
items for MCC approval prior to the compact end date:
* a list of the types of documents the partner government will retain,
* a document retention schedule, and:
* a brief description of the form and manner in which the documents
will be stored.[Footnote 23]
MCC's compact closure guidelines do not provide a sample document
retention schedule specifying standard types of compact-related
information that most compacts would need to retain or provide.
All five program closure plans that we reviewed contained some
discussion of filing and storing documents, but each MCA addressed the
guidelines' three requirements differently. Such variation in
approaches to scheduling and storing compact documentation will make
it more difficult for MCC to verify that standard compact information
is being retained in all partner countries after the compacts have
closed.
Types of documents to be retained. The program closure plans for the
Armenia, Ghana, and Mali compacts specified that the respective
partner governments would retain all compact-related information. The
program closure plan for the Benin compact did not list the types of
documents that the government would retain but stated that the MCA
would provide further information in the document retention schedule.
The program closure plan for the El Salvador compact stated that the
government, through a contractor, would retain original files related
to personnel, projects, procurement, finance, monitoring and
evaluation, and studies.
Document retention schedule. The MCAs' document retention schedules
also varied. Armenia and Benin did not provide document retention
schedules.[Footnote 24] El Salvador provided a comprehensive listing,
by category, of all documents to be retained; however, it provided
this list for the purposes of our review in April 2013, after the
compact end date. Ghana's schedule, submitted after the compact end
date but within the 3-month compact closure period, specified document
types to be retained. Mali provided an undated printout of its
electronic file system. According to MCC officials, the disparity
among the MCAs' document retention schedules stemmed from
insufficiently specific guidance provided by MCC.
Form and manner of document storage. The MCAs' program closure plans
specified varying forms and manners of storage for compact-related
information after compact closure. According to the plans:
* Armenia will store the documents at three different government
agencies: the state archives, the Ministry of Transport and
Communications, and the Foreign Financing Projects Management Center
(a foreign donor coordination unit);
* Benin will store the documents at its national archives;
* El Salvador has made a contractor responsible for the safekeeping of
compact-related files and documents;
* Ghana's MCA will continue as a foreign donor coordination unit after
compact closure and will retain all MCC documents; and:
* Mali will store compact-related information at the Office of the
Secretary General of the President (the "Office of the Segal"), which
was the office of the principal government representative under the
compact.
Countries' Ability to Provide Specific Documents Varied:
Our test of MCC's ability to retrieve compact-related information from
the five countries produced varying results that depended on the
stability of the governments. Four of the governments provided all or
most of the documents we requested. In contrast, Mali's government,
which is in transition, provided none of the requested documents.
Figure 1 displays the test results.
Figure 1: Number of Requested Documents Returned within 30 Days, by
Country:
[Refer to PDF for image: stacked horizontal bar graph]
MCC country: Armenia;
Number of documents requested: 13;
Number of documents received: 15.
MCC country: Benin;
Number of documents requested: 20;
Number of documents received: 20.
MCC country: El Salvador;
Number of documents requested: 14;
Number of documents received: 18.
MCC country: Ghana;
Number of documents requested: 17;
Number of documents received: 20.
MCC country: Mali;
Number of documents requested: 0;
Number of documents received: 20.
Source: GAO.
Note: El Salvador provided two additional documents after the 30-day
period.
[End of figure]
Owing to its policy of relying on partner governments to retain and
store compact-related information, MCC lost access to this information
for 2 of the 11 closed compacts when, because of political turmoil, it
terminated its compacts with Mali and Madagascar. Mali's government
has been in transition since March 2012, when the administration at
that time was overthrown. According to MCC, the transitional
government in Mali will establish an office to handle post-compact
issues but has not provided a point of contact. As a result, MCC
officials reported that although they believe the information related
to the Mali and Madagascar compacts exists and has been maintained in
an organized fashion, they are currently unable to access the
requested documents. MCC has previously noted that political turmoil
in Madagascar, whose government was overthrown in 2009, impeded MCC's
ability to access documents.[Footnote 25]
MCC officials stated that they considered the response rate to our
test to be good, particularly since the people retrieving the
documents were not necessarily the same people who created or stored
them. Previously, MCC has stated that its ability to retrieve
documents from partner countries is reliant on its ability to access
key individuals.[Footnote 26] MCC officials further stated that the
difference in document return rates among the four countries that
provided all or most of the requested documents may have been due to
our test methodology. According to these officials, some of the
documents we requested were not "critical path" documents, and our
descriptions of the documents may not have been specific enough to
allow the partner countries to identify them. However, all of the
documents we requested were used in audits by the USAID's Office of
the Inspector General. They thus serve as examples of the types of
documents that might be needed to support future audits--one of the
purposes for which MCC requires the partner governments to retain
compact-related information for at least 5 years.
Conclusions:
Records and information management is important in all government
agencies, in part because it helps ensure that the agencies remain
transparent and accountable to the public and allows for congressional
and executive branch oversight. MCC established a records management
program that, according to NARA, is comparable to many others in the
federal government. Yet, as an international aid agency providing
bilateral assistance to partner governments, MCC's situation regarding
records and information management is atypical: Much of the
information related to its core business is generated by the partner
governments' accountable entities, the MCAs. In accordance with NARA
guidelines, MCC has established policies and guidelines stipulating
that the MCAs must provide it with the compact management information
it classifies as U.S. federal records. However, because its policies
do not call for, and it does not conduct, systematic reviews of the
records it receives, MCC cannot be sure that it is meeting the Federal
Records Act's requirement that it preserve all records documenting its
functions, activities, decisions, and other important transactions.
MCC also has established policies that require partner governments to
retain other compact-related information for at least 5 years after
the compact closes, to support audits and its own program evaluations.
However, for the five closed compacts that we reviewed, the variations
in the partner governments' plans for retaining compact-related
information could make it difficult for MCC to verify that the
appropriate information is being retained. While MCC provides the
partner governments a list specifying what types of documents it
classifies as compact management records needed for storage at MCC
headquarters, it does not provide such a list for other compact-
related information expected to be retained in-country by the partner
governments. A standardized schedule of compact-related information to
be retained by each partner government would improve MCC's ability to
find and use this information and increase MCC's efficiency in
comparing similar information across compacts.
Last, while four of the five partner governments were able to provide
the information we requested in our test of MCC's system, the
inability of one country--Mali, whose government is in transition--to
produce any of the requested documents calls into question MCC's
policy of relying on partner governments to retain and store most
compact-related information. While the situation in Mali is unusual,
the recent political turmoil in Madagascar, another former MCC
partner, shows that such situations are not unique. Given that the
countries that MCC targets for aid are, by definition, in transition,
MCC could benefit from taking precautionary steps--such as weighing
the costs and benefits of storing more compact-related information at
MCC headquarters--to protect and ensure access to compact-related
information.
Recommendations:
We recommend that MCC's Chief Executive Officer take the following
three actions to strengthen MCC's records and information management
program:
1. Develop a policy requiring--and conduct--periodic reviews of each
set of compact management records that MCC receives from partner
governments, to ensure that the records are complete.
2. Revise program closure guidelines to include a sample document
retention schedule, specifying standard types of compact-related
information that most compacts would need to retain.
3. Review MCC's policy of delegating the storage of compact-related
information to partner governments, weighing the costs and benefits of
storing more of this information at MCC headquarters.
Agency Comments and Our Evaluation:
In written comments about a draft of this report, MCC stated that it
agrees with our recommendations and is taking steps to implement them.
* With respect to our first recommendation--to develop a policy
requiring, and to conduct, periodic reviews of each set of compact
management records received from partner governments--MCC stated that,
although it has been conducting selected reviews of compliance with
compact records management requirements, making the practice more
systematic would be useful. To that end, its Department of Compact
Operations will ensure that reviews of MCC and MCA compliance with
compact management records polices are incorporated in both
implementation and close-out procedures.
* With respect to our second recommendation--to revise program closure
guidelines to include a sample document retention schedule--MCC stated
that it will consider how best to structure a standardized list of
core documents that also preserves a country's flexibility to tailor
its document retention schedule in light of local laws and the
specific types of compact projects.
* With respect to our third recommendation--to weigh the costs and
benefits of storing more compact-related information at MCC
headquarters--MCC stated that it will review, and revise as necessary,
its Policy and Procedures for Compact-Related Federal Record Keeping
to ensure that it specifies all documents that should be defined as
federal records.
We have reprinted MCC's comments in appendix III. We have also
incorporated technical comments from MCC in our report where
appropriate.
NARA also provided technical comments on a draft of this report, which
we have incorporated as appropriate. In addition, NARA stated that
having reviewed our description of MCC's classification of federal
records and "non-records" as they pertain to the MCAs, it will contact
MCC to ensure that proper classification is occurring.
We are sending copies of this report to interested congressional
committees and the Millennium Challenge Corporation. In addition, this
report is available at no charge on the GAO website at [hyperlink,
http://www.gao.gov].
If you or your staff members have any questions about this report,
please contact David Gootnick at (202) 512-3149 or gootnickd@gao.gov.
Contact points for our Offices of Congressional Relations and Public
Affairs may be found on the last page of this report. GAO staff
members who made major contributions to this report are listed in
appendix IV.
Sincerely yours,
David Gootnick:
Director:
International Affairs and Trade:
[End of section]
Appendix I: Objectives, Scope, and Methodology:
Our objectives were to (1) examine the Millennium Challenge
Corporation's (MCC) records and information management program and
practices and (2) assess partner-country governments' implementation
of MCC guidelines for retention and storage of compact-related
information.
To examine MCC's records and information management program and
practices, we reviewed MCC's policies and guidelines regarding records
and information management, focusing in particular on three documents:
Records and Information Management Policy (June 2011), Policy and
Procedures for Compact-Related Federal Recordkeeping (September 2012),
and Program Closure Guidelines (May 2011). We also reviewed the
results of MCC's annual self-assessment surveys from 2009 through
2012, a tool that the National Archives and Records Administration
(NARA) developed to assess agencies' self-compliance with the Federal
Records Act and other laws and regulations related to records
management, and we reviewed relevant laws, regulations, and circulars
produced by the Office of Management and Budget. In addition, we
interviewed officials at MCC and NARA.
To assess partner governments' implementation of MCC's guidelines for
retention and storage of compact-related information, we selected five
closed compacts--Armenia's, Benin's, El Salvador's, Ghana's, and
Mali's--to use as case studies. We chose these compacts because they
closed after May 2011 and therefore were subject to MCC's Program
Closure Guidelines, which were finalized that month. We reviewed the
documentation that the partner governments or their accountable
entities (usually referred to as Millennium Challenge Accounts, or
MCAs) had provided to MCC in response to those guidelines. Regarding
MCC's requirement that the partner governments make provisions for the
form and manner of document storage, we reviewed the compacts' program
closure plans to ensure that provisions for document storage were
included, but we did not verify that specific storage requirements--
such as security and acclimatization--were met.
We also conducted a test of MCC's ability to retrieve compact-related
information from partner governments after compact closure. For this
test, we asked MCC to request that the partner governments for the
case-study compacts provide copies of documents that the U.S. Agency
for International Development's (USAID) Office of the Inspector
General (OIG) had collected during the course of performance and
financial audits of the five countries. [Footnote 27] We selected the
audits from a list that the OIG provided, and we drew from those
audits a random sample of documents that we requested from the partner
governments. We used OIG files because it has conducted audits in all
5 countries, whereas GAO has not.
* Selection of performance and financial audits. The OIG provided a
list of 10 performance and 4 financial audits that it considered
relevant to our case studies. We removed one performance audit from
the list, because the OIG had conducted the audit prior to any MCC
compact's entry into force and the audit therefore would not yield
valid documents. We then selected three performance audits and one
financial audit to review for each of the case-study compacts (except
Armenia's, for which the OIG did not conduct a financial audit).
Several of the performance audits on the OIG's list covered more than
one of the case-study compacts. Because Armenia and Benin's compacts
were both covered in two performance audits and Mali's compacts was
covered by three performance audits, we included all of these audits
in our sample. Because Ghana's and El Salvador's compacts were each
covered by more than three performance audits, we randomly selected
among the relevant audits. Because the OIG conducted only one
financial audit per compact (except Armenia's), we selected all of the
listed financial audits. See table 3 for a list of the audits that we
selected from which we randomly drew supporting documents for our case
studies.
Table 3: Selected USAID Office of the Inspector General Audit Reports,
by Title and Number:
Report title: Audit of the Millennium Challenge Corporation's
Resettlement Activities;
Report number: M-000-13-002-P.
Report title: Review of Millennium Challenge Corporation's Branding and
Marking Policies and Practices;
Report number: M-000-12-002-S.
Report title: Review of the Millennium Challenge Corporation's Compact
Modifications;
Report number: M-000-12-006-S.
Report title: Audit of Millennium Challenge Corporation-Funded Programs
in El Salvador;
Report number: M-000-11-005-P.
Report title: Review of Millennium Challenge Corporation-Funded
Contracts with Government-Owned Enterprises in Mali;
Report number: M-000-11-004-S.
Report title: Audit of the Millennium Challenge Corporation's Access to
Markets Program in Benin;
Report number: M-000-10-001-P.
Report title: Audit of the Agricultural Credit Program in Ghana;
Report number: M-000-09-005-P.
Report title: Audit of Compliance with Procurement Requirements by the
Millennium Challenge Corporation and its Compact Countries;
Report number: M-000-08-002-P.
Report title: Review of Millennium Challenge Corporation Funded
Projects in Benin;
Report number: M-000-12-005-S.
Report title: Limited Scope Review of Millennium Challenge Corporation
(MCC) Resources Managed by the Millennium Development Authority (MiDA),
Under the Compact Agreement Between MCC and the Government of Ghana;
Report number: M-000-11-002-S.
Report title: Limited Scope Review of Millennium Challenge Corporation
(MCC) Resources Managed by the Millennium Challenge Account-Mali (MCA-
Mali), Under the Compact Agreement Between the MCC and the Government
of Mali;
Report number: M-000-10-004-S.
Report title: Millennium Challenge Corporation and Accountable Entities
Compliance with "Policies and Procedures for Common Payment System";
Report number: M-000-09-001-S.
Source: USAID Office of the Inspector General.
[End of table]
* Random sample of audit documents. Each audit contained multiple
files, from which we randomly drew a sample of 93 documents: 20
documents for Benin's, Ghana's, and Mali's compacts; 18 documents for
El Salvador's compact; and 15 documents for Armenia's compact. The
number of documents that we sampled per compact varied for two
reasons: (1) because the OIG has not conducted a financial audit for
Armenia's compact, we were unable to select any financial-audit-
related documents for our sample, and (2) the performance audit files
for El Salvador's compact contained only 18 appropriate documents.
Table 4 shows the number of documents we sampled per compact, by type
of audit (financial or performance).
Table 4: Number of Documents in Random Sample, per MCC Compact and
Type of Audit:
Country: Armenia;
Financial audit documents: n/a;
Performance audit documents: 15;
Total: documents: 15.
Country: Benin;
Financial audit documents: 5;
Performance audit documents: 15;
Total: documents: 20.
Country: El Salvador;
Financial audit documents: 3;
Performance audit documents: 15;
Total: documents: 18.
Country: Ghana;
Financial audit documents: 5;
Performance audit documents: 15;
Total: documents: 20.
Country: Mali;
Financial audit documents: 5;
Performance audit documents: 15;
Total: documents: 20.
Country: Total;
Financial audit documents: 18;
Performance audit documents: 75;
Total: documents: 93.
Source: GAO.
[End of table]
* Requests for sampled documents. We provided a list of the randomly
sampled documents for each case-study compact to MCC. We identified
each document using, as appropriate, its title, date, and other
identifying information (e.g., contract number, payment order number,
beneficiary name, letter recipient). For Benin's, Ghana's, El
Salvador's, and Mali's compacts, we listed the document titles and
other information in the document's original language (English,
French, or Spanish). For Armenia, we translated the title and other
information into English when necessary. We asked MCC to share these
lists with the five partner governments and to request that they send
us copies of the documents, either electronic or paper, within 20
business days, in keeping with the Freedom of Information Act's (FOIA)
requirement. In response to an MCC comment that the documents we
requested would not, as "non-records," be subject to the FOIA
requirement, we have reported the numbers of documents that the
partner governments returned within 30 calendar days--the requirement
stated in MCC's Program Closure Guidelines. However, the numbers of
documents returned within 20 business days were identical to the
numbers returned within 30 calendar days.
* Verification of requested documents. To verify that the partner
governments provided the documents we requested, we conducted two
separate comparisons of the documents we received with corresponding
electronic copies, which USAID's OIG had allowed us to retain in our
files.
We conducted this performance audit from September 2012 to June 2013
in accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe the
evidence obtained provides a reasonable basis for our findings and
conclusions based on our audit objectives.
[End of section]
Appendix II: MCC Scores on NARA Self-Assessment Survey, 2009-2012:
Since 2009, the National Archives and Records Administration (NARA)
has administered a survey to assess federal agencies' compliance with
federal records-keeping laws and regulations. The Millennium Challenge
Corporation (MCC) has received the following scores: 92 (2009), 83
(2010), 76 (2011), and 77 (2012). See tables 5 through 8 below for
more information.
Table 5: MCC Scores on NARA Self-Assessment Survey, by Section, 2009:
Survey sections: Records management program;
MCC score: 22;
Total possible score: 26;
Percentage: 85%.
Survey sections: Records disposition;
MCC score: 18;
Total possible score: 18;
Percentage: 100%.
Survey sections: Email;
MCC score: 30;
Total possible score: 30;
Percentage: 100%.
Survey sections: Electronic records;
MCC score: 14;
Total possible score: 18;
Percentage: 78%.
Survey sections: Vital records;
MCC score: 8;
Total possible score: 8;
Percentage: 100%.
Survey sections: Total score;
MCC score: 92;
Total possible score: 100;
Percentage: 92%.
NARA rating of overall risk factor: Low.
Source: GAO analysis of MCC results on NARA survey.
[End of table]
Table 6: MCC Scores on NARA Self-Assessment Survey, by Section, 2010:
Survey sections: Records management program;
MCC score: 14;
Total possible score: 14;
Percentage: 100%.
Survey sections: Records management activities;
MCC score: 12;
Total possible score: 15;
Percentage: 80%.
Survey sections: Electronic records;
MCC score: 12;
Total possible score: 15;
Percentage: 80%.
Survey sections: Records disposal;
MCC score: 16;
Total possible score: 18;
Percentage: 89%.
Survey sections: Vital records;
MCC score: 8;
Total possible score: 8;
Percentage: 100%.
Survey sections: Records management training;
MCC score: 21;
Total possible score: 30;
Percentage: 70%.
Survey sections: Total score;
MCC score: 83;
Total possible score: 100;
Percentage: 83%.
NARA rating of overall risk factor: Moderate.
[End of table]
Source: GAO analysis of MCC results on NARA survey.
Table 7: MCC Scores on NARA Self-Assessment Survey, by Section, 2011:
Survey sections: Records management activities;
MCC score: 20;
Total possible score: 20;
Percentage: 100%.
Survey sections: Oversight/compliance;
MCC score: 31;
Total possible score: 37;
Percentage: 84%.
Survey sections: Records disposition;
MCC score: 16;
Total possible score: 18;
Percentage: 89%.
Survey sections: Electronic records;
MCC score: 9;
Total possible score: 25;
Percentage: 36%.
Survey sections: Total score;
MCC score: 76;
Total possible score: 100;
Percentage: 76%.
NARA rating of overall risk factor: Moderate.
Source: GAO analysis of MCC results on NARA survey.
[End of table]
Table 8: MCC Scores on NARA Self-Assessment Survey, by Section, 2012:
Survey sections: Records management activities;
MCC score: 21;
Total possible score: 21;
Percentage: 100%.
Survey sections: Oversight/compliance;
MCC score: 23;
Total possible score: 31;
Percentage: 74%.
Survey sections: Records disposition;
MCC score: 15;
Total possible score: 15;
Percentage: 100%.
Survey sections: Electronic records;
MCC score: 18;
Total possible score: 33;
Percentage: 55%.
Survey sections: Total score;
MCC score: 77;
Total possible score: 100;
Percentage: 77%.
NARA rating of overall risk factor: Moderate.
Source: GAO analysis of MCC results on NARA survey.
[End of table]
[End of section]
Appendix III: Comments from the Millennium Challenge Corporation:
Millennium:
Challenge Corporation:
United States of America:
875 Fifteenth Street NW:
Washington, DC 20005-2221:
p: (202) 521-3600:
f: (202) 521-3700:
[hyperlink, http://www.mcc.gov]
June 3, 2013:
David Gootnick:
Director, International Affairs and Trade:
U.S. Government Accountability Office:
441 G Street, NW:
Washington, DC 20548:
Re: MCC Response to Draft Report GAO-13-615:
Dear Mr. Gootnick:
Thank you for the opportunity to review and comment on the U.S.
Government Accountability Office's (GAO) draft report, "Millennium
Challenge Corporation: Review of Compact Records and Information
Management Program."
We were pleased to see the report acknowledge the challenges the
Millennium Challenge Corporation (MCC) faces working in countries
characterized by major operational and capacity issues. As the report
notes, four of the five countries included in the review were able to
provide all or most of the documents requested, and the exception —
Mali — is literally in the midst of a civil war. As the draft report
recognizes, MCC has put significant effort into establishing policies
on records management. In regard to meeting federally-mandated record-
keeping requirements, the GAO audit did not identify any material
failure to adhere to required standards. MCC, as the report notes, has
scored as average among much longer-established Federal agencies, and
we are working to improve those scores.
As discussed in the draft report, since MCC was created nine years
ago, the agency has established a records and information management
program; has established record series and retention schedules with
the National Archives and Records Administration (NARA); and has
issued several policies on records, including Records and Information
Management Policy, the Policy and Procedures for Compact-Related
Federal Recordkeeping, which identifies numerous compact-related
documents as Federal Records in its Annex 1, and MCC Program Closure
Guidelines which provides guidance to accountable entities (MCAs)
regarding the maintenance of non-records.
However, as the draft report concludes, there are areas in which MCC
can improve its records management performance, something to which MCC
is committed as a matter of principle. In that spirit, MCC found the
recommendations set out in the GAO report of its records management
review very helpful. The report makes three recommendations. We are in
agreement with them and are already taking steps to implement them.
Please find more detailed responses below:
1. Develop a policy requiring-2nd conduct-periodic reviews of each set
of compact management records that MCC receives from partner
governments, to ensure that the records are complete. MCC has been
conducting selected reviews of compliance with compact records
management requirements. However, MCC agrees that making this more
systematic would be useful and therefore agrees with this
recommendation. MCC's Department of Compact Operations will ensure
that reviews of MCC and MCA compliance with compact management records
policies are incorporated in both implementation and close-out
procedures.
2. Revise program closure guidelines to include a sample document
retention schedule, specifying standard types of compact-related
information that most compacts would need to retain. MCC has provided
sample schedules in the past and has worked with MCAs on the
development of country-specific schedules. It is necessary to retain
the flexibility to tailor document retention schedules to each compact
in order to ensure compliance with the laws of the partner country
and/or to accurately document a specific compact. However, MCC agrees
in principle that a standardized listing of core documents would be
useful, so long as it is not read to exclude documents that may not be
listed but which should be retained due to the laws in the specific
partner country and/or subject of the compact, and will consider how
best to structure such a list.
3. Review MCC's policy of delegating the storage of compact-related
information to partner governments, weighing the costs and benefits of
storing more of this information at MCC headquarters. We agree with
this recommendation in that it recognizes the need for continuous
review and weighing of costs and benefits. We note, however, that MCC
currently retains all compact-related Federal Records and has not
delegated this responsibility to the MCA's. We also note that each MCA
is subject to the laws of the partner country and may be required to
retain certain documents pursuant to local law, such that it is not
appropriate to store the original documents at MCC headquarters.
Nonetheless, MCC reviews and updates its policies on an ongoing basis,
and we will review and revise as necessary Annex I to the Policy and
Procedures for Compact-Related Federal Recordkeeping, to ensure that
it includes all documents that should be defined as Federal Records.
We would like to take this opportunity to thank you and your staff for
the professional manner in which this audit was conducted and for the
opportunity to provide additional information and feedback on the GAO
draft report.
Sincerely,
Signed by:
Frances Reid:
Senior Investment and Risk Officer:
Office of the Chief Executive:
Millennium Challenge Corporation:
[End of section]
Appendix IV: GAO Contact and Staff Acknowledgments:
GAO Contact:
David Gootnick, (202) 512-3149, or gootnickd@gao.gov:
Staff Acknowledgments:
In addition to the contact named above, Emil Friberg, Jr. (Assistant
Director) and Miriam Carroll Fenton made key contributions to this
report. Additional technical assistance was provided by Reid Lowe,
Christopher Mulkins, Justin Fisher, Martin de Alteriis, Nancy Hunn,
Mark Bird, Etana Finkler, and Ernie Jackson.
[End of section]
Footnotes:
[1] MCC commits funding when a compact is signed and obligates funds
after the compact enters into force. As of May 2013, MCC had signed
initial compacts with, in chronological order, Madagascar, Honduras,
Cape Verde, Nicaragua, Georgia, Benin, Vanuatu, Armenia, Ghana, Mali,
El Salvador, Mozambique, Lesotho, Morocco, Mongolia, Tanzania, Burkina
Faso, Namibia, Senegal, Moldova, the Philippines, Jordan, Malawi,
Indonesia, and Zambia. The compacts with Honduras, Cape Verde,
Georgia, Vanuatu, Nicaragua, Armenia, Benin, Ghana, and El Salvador
have ended. In addition, MCC terminated the compacts with Madagascar
and Mali because both countries underwent a nondemocratic change of
government. In February 2012, MCC signed a second compact with Cape
Verde.
[2] Codified at 44 U.S.C., chapters 21, 29, 31, and 33.
[3] See GAO, Information Management: The Challenges of Managing
Electronic Records, [hyperlink,
http://www.gao.gov/products/GAO-10-838T] (Washington, D.C.: June 17,
2010).
[4] See GAO, Standards for Internal Control in the Federal Government,
[hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1]
(Washington, D.C.: November 1999).
[5] We chose these countries because they were subject to MCC's
Program Closure Guidelines, which were finalized in May 2011.
[6] We focused on the following three documents: Records and
Information Management Policy (June 2011), Policy and Procedures for
Compact-Related Federal Recordkeeping (September 2012), and Program
Closure Guidelines (May 2011).
[7] USAID's Office of the Inspector General is also responsible for
overseeing MCC activities.
[8] We requested 20 documents each from Benin, Ghana, and Mali. We
requested 18 documents from El Salvador and 15 documents from Armenia
because these were the complete sets of appropriate documents from the
Inspector General's audit files.
[9] In addition to compact agreements, MCC provides foreign assistance
through its Threshold Program, which is designed to assist a country
in becoming compact eligible by supporting target policy and
institutional reforms.
[10] The relevant provisions of the Federal Records Act of 1950 and
subsequent records management statutes are largely codified in
chapters 21, 29, 31, and 33 of Title 44 of the U.S. Code.
[11] The definition of a record is given at 44 U.S.C. 3301.
[12] 44 U.S.C. § 3102.
[13] Under the Federal Records Act, NARA shares a number of records
management responsibilities and authorities with the General Services
Administration. In addition, the Office of Management and Budget has
records management oversight responsibilities under the Paperwork
Reduction Act and the E-Government Act.
[14] MCC hired a records management officer in 2006 to establish the
records and information management program.
[15] A "record series" is the basic unit for organizing and
controlling files. It is a group of files or documents kept together
because they relate to a particular subject or function, result from
the same activity, document a specific type of transaction, take a
particular physical form, or have some other relationship arising out
of their creation, receipt, maintenance, or use.
[16] The document was originally titled "Recordkeeping Procedures for
the Implementation of Compacts Policy."
[17] MCC considers other compact-related information to be "non-
records."
[18] MCC compact management records fall into 10 categories: (1)
compact core document, (2) program oversight, (3) MCC decisions and
approvals, (4) program procurement, (5) monitoring and evaluation, (6)
environment and social assessment, (7) infrastructure, (8) fiscal
accountability, (9) program MCA documents, and (10) compact close and
post-compact.
[19] In addition, the five compacts we reviewed contained a provision
that requires the partner governments to maintain compact documents
for at least 5 years after compact closure.
[20] Prior to compact signature, MCC's Country Team Leader is
responsible for ensuring that the appropriate records are retained.
[21] GAO, Standards for Internal Control in the Federal Government,
[hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1]
(Washington, DC: November 1999.)
[22] According to NARA, it has not received a specific appeal for
assistance from MCC. However, NARA noted that smaller agencies that
have limited resources, like MCC, and experience similar challenges
have generally appealed for assistance.
[23] According to the Program Closure Guidelines, the documents must
be maintained at a site that is secure, locked, and acclimatized to
ensure the documents' viability and the proper treatment of sensitive
information.
[24] Armenia provided a draft contract that it would sign to create
physical archives. Benin provided the protocol that it had signed with
the government entity that maintains the country's archives.
[25] In June 2009, MCC terminated its compact with Madagascar because
of an undemocratic transfer of power in March of that year. MCC has
stated that it has no diplomatic authority to independently engage
with the post-coup government in Madagascar.
[26] MCC does not require that MCAs designate points of contact for
document retention issues. However, MCC guidelines do require each MCA
to identify designated representatives who will serve as the primary
points of contact for any monitoring-and evaluation-related obligation
of the government.
[27] USAID's Office of the Inspector General is responsible for
overseeing MCC activities.
[End of section]
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Washington, DC 20548.
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